Worthy v. Phenix City, No. 17-14718 (11th Cir. 2019)Annotate this Case
Plaintiffs filed suit challenging the city's red light ordinance, which permitted the installation and operation of cameras to enforce traffic-control-device violations at certain intersections. The district court dismissed the case based on lack of Article III standing.
Although the Eleventh Circuit held that plaintiffs had standing to bring their damages claims, their constitutional claims must nonetheless be dismissed because they failed to sufficiently allege that they suffered a violation of their constitutional rights.The court held that the dismissal of plaintiffs' federal claims was warranted because the complaint failed to state a claim for which relief can be granted. In this case, plaintiffs alleged that the ordinance imposed a criminal penalty without providing constitutionally sufficient procedural safeguards. However, the ordinance imposed a civil penalty, and thus the procedures prescribed by the ordinance were constitutionally sufficient. Because the court held that plaintiffs have not stated any federal claims, it declined to consider the state law claims. Accordingly, the court vacated and remanded with instructions.